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When ERISA Lets Your Insurer Withhold Disability Benefits to Recoup a Social Security Overpayment: A New York Federal Court Upholds Hartford’s Offset
In Doolittle v. Hartford Life and Accident Insurance Company, No. 1:25-cv-00148 (BKS/CBF), 2026 WL 3135297 (N.D.N.Y. Oct. 20, 2026), Chief U.S. District Judge Brenda K. Sannes granted summary judgment to…
Does an ERISA Remand Revive the “Fiduciary Exception”? Federal Court Orders Disability Insurer to Log Attorney Communications About a Remanded Claim
In Collier v. Lincoln Life Assurance Company of Boston, No. 8:20-cv-00839-JVS-KESx, 2026 WL 3126569 (C.D. Cal. Oct. 5, 2026), a federal magistrate judge confronted a question that arises whenever an…
Use It or Lose It: Court Won’t Strike Guardian’s Declaration in an ERISA Preemption Dispute After the Claimant Sat Out Discovery
In Hannon v. Guardian Life Insurance Company of America, No. 25-13431-LTS, 2026 WL 3093200 (D. Mass. Oct. 16, 2026), a Massachusetts federal court confronted a recurring question in ERISA litigation:…
When an Employer’s Premium Withholding Can’t Rewrite the Plan: District Court Denies ERISA Life Insurance Benefits and Civil Penalties on a Default Judgment Motion
In Thomas v. UACJ Automotive Whitehall Industries, Inc., No. 1:25-cv-944, 2026 WL 3056814 (W.D. Mich. Oct. 13, 2026), Chief United States District Judge Hala Y. Jarbou denied a widower’s renewed…
When a Severance Release Does Not Reach Your ERISA Claim: C.D. California Holds a General Release Cannot Waive a Disability Claim That Had Not Yet Accrued
In Cude v. Lincoln National Life Insurance Company, No. 8:25-cv-00123-AH-KESx, 2026 WL 3036131 (C.D. Cal. Oct. 9, 2026), District Judge Anne Hwang of the United States District Court for the…
En Banc Eleventh Circuit Holds That ERISA Does Not Require Administrative Exhaustion of Statutory Claims, Including Breach of Fiduciary Duty Claims, and Overrules Four Decades of Circuit Precedent
In Bolton v. Inland Fresh Seafood Corp. of America, Inc., No. 24-10084, --- F.4th ----, 2026 WL 3056461 (11th Cir. Oct. 13, 2026), sitting en banc, the Eleventh Circuit overruled…
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